03-031 - Denti-Cal Complaint - Attorney General - State of California

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laundered money of a value in excess of Fifty Thousand Dollars ($50,000), within the meaning
of Penal Code §186.10(c)(1)(A).
COUNT 22
On or about or between December 30, 1999 and January 13, 2000, in the County of Los
Angeles, State of California, defendant, Julio Javier Romo, committed the crime of MONEY
LAUNDERING, in that he did willfully and unlawfully conduct, or aid and abet, transactions
involving monetary instruments through one or more financial institutions, with the knowledge
that the monetary instruments represent, and are derived directly or indirectly, from the proceeds
of a criminal activity in violation of Penal Code §186.10(a)(2), a felony
COUNT 23
On or about or between February 4, 2000 and February 9, 2000, in the County of Los
Angeles, State of California, defendant, Julio Javier Romo, committed the crime of MONEY
LAUNDERING, in that he did willfully and unlawfully conduct, or aid and abet, transactions
involving monetary instruments through one or more financial institutions, with the knowledge
that the monetary instruments represent, and are derived directly or indirectly, from the proceeds
of a criminal activity in violation of Penal Code §186.10(a)(2), a felony
COUNT 24
On or about or between March 16, 2000, and April 15, 2000, in the County of Los
Angeles, State of California, defendants, Julio Javier Romo and Zubin Plasencia, committed
the crime of IDENTITY THEFT in that said defendants, did willfully and unlawfully obtain
personal identifying information of Dan Thanh Le, DDS, without authorization, and used that
information for an unlawful purpose and to obtain, or attempt to obtain credit, goods, services, or
medical information through the use of said personal identifying information, without the consent
of Dan Thanh Le, DDS, in violation of Penal Code §530.5(a), a felony.
22.
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